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TITLE 16ECONOMIC REGULATION
PART 1RAILROAD COMMISSION OF TEXAS
CHAPTER 3OIL AND GAS DIVISION
RULE §3.46Fluid Injection into Productive Reservoirs

  (6) An areal variance granted under the provisions of this subsection may be modified, terminated, or suspended by the commission after notice and opportunity for hearing is provided to each person shown on commission records to operate an oil or gas lease in the area in which the proposed modification, termination, or suspension would apply. If a hearing on a proposal to modify, terminate, or suspend an areal variance is held, any applications filed subsequent to the date notice of hearing is given must include the area-of-review information required under paragraph (1) of this subsection pending issuance of a final order.

(f) Casing. Injection wells shall be cased and the casing cemented in compliance with §3.13 of this title (relating to Casing, Cementing, Drilling, and Completion Requirements) in such a manner that the injected fluids will not endanger oil, gas, or geothermal resources and will not endanger freshwater formations not productive of oil, gas, or geothermal resources.

(g) Special equipment.

  (1) Tubing and packer. Wells drilled or converted for injection shall be equipped with tubing set on a mechanical packer. Packers shall be set no higher than 200 feet below the known top of cement behind the long string casing but in no case higher than 150 feet below the base of usable quality water. For purposes of this section, the term "tubing" refers to a string of pipe through which injection may occur and which is neither wholly nor partially cemented in place. A string of pipe that is wholly or partially cemented in place is considered casing for purposes of this section.

  (2) Pressure valve. The wellhead shall be equipped with a pressure observation valve on the tubing and for each annulus of the well.

  (3) Exceptions. The commission or its delegate may grant an exception to any provision of this paragraph upon proof of good cause. If the commission or its delegate denies an exception, the operator shall have a right to a hearing upon request. After hearing, the examiner shall recommend a final action by the commission.

(h) Well record. Within 30 days after the completion or conversion of an injection well, the operator shall file in duplicate in the district office a complete record of the well on the appropriate form which shows the current completion.

(i) Monitoring and reporting.

  (1) The operator shall monitor the injection pressure and injection rate of each injection well on at least a monthly basis, or on a more frequent basis for a disposal well permitted under this section as required by the commission under conditions described in subsection (b)(1)(D) of this section.

  (2) The results of the monitoring shall be reported annually, or on a more frequent basis for a disposal well permitted under this section as required by the commission under conditions described in subsection (b)(1)(D) of this section, to the commission on the prescribed form.

  (3) All monitoring records shall be retained by the operator for at least five years.

  (4) The operator shall report to the appropriate District Office within 24 hours any significant pressure changes or other monitoring data indicating the presence of leaks in the well.

(j) Testing.

  (1) Purpose. The mechanical integrity of an injection well shall be evaluated by conducting pressure tests to determine whether the well tubing, packer, or casing have sufficient mechanical integrity to meet the performance standards of this rule, or by alternative testing methods under paragraph (5) of this subsection.

  (2) Applicability. Mechanical integrity of each injection well shall be demonstrated in accordance with provisions of paragraphs (4) and (5) of this subsection prior to initial use. In addition, mechanical integrity shall be tested periodically thereafter as described in paragraph (3) of this subsection.

  (3) Frequency.

    (A) Each injection well completed with surface casing set and cemented through the entire interval of protected usable-quality water shall be tested for mechanical integrity at least once every five years.

    (B) In addition to testing required under subparagraph (A), each injection well shall be tested for mechanical integrity after every workover of the well.

    (C) An injection well that is completed without surface casing set and cemented through the entire interval of protected usable-quality ground water shall be tested at the frequency prescribed in the injection permit.

    (D) The commission or its delegate may prescribe a schedule and mail notification to operators to allow for orderly and timely compliance with the requirements in subparagraph (A) and subparagraph (B) of this paragraph. Such testing schedule shall not apply to an injection well for which an injection well permit has been issued but the well has not been drilled or converted to injection.

  (4) Pressure tests.

    (A) Test pressure.

      (i) The test pressure for wells equipped to inject through tubing and packer shall equal the maximum authorized injection pressure or 500 psig, whichever is less, but shall be at least 200 psig.

      (ii) The test pressure for wells that are permitted for injection through casing shall equal the maximum permitted injection pressure or 200 psig, whichever is greater.

    (B) Pressure stabilization. The test pressure shall stabilize within 10% of the test pressure required in subparagraph (A) of this paragraph prior to commencement of the test.

    (C) Pressure differential. A pressure differential of at least 200 psig shall be maintained between the test pressure on the tubing-casing annulus and the tubing pressure.

    (D) Test duration. A pressure test shall be conducted for a duration of 30 minutes when the test medium is liquid or for 60 minutes when the test medium is air or gas.

    (E) Pressure recorder. Except for tests witnessed by a commission representative or wells permitted for injection through casing, a pressure recorder shall be used to monitor and record the tubing-casing annulus pressure during the test. The recorder clock shall not exceed 24 hours. The recorder scale shall be set so that the test pressure is 30 to 70% of full scale, unless otherwise authorized by the commission or its delegate.

    (F) Test fluid.

      (i) The tubing-casing annulus fluid used in a pressure test shall be liquid for wells that inject liquid unless the commission or its delegate authorizes use of a different test fluid for good cause.

      (ii) The tubing-casing annulus fluid used in a pressure test shall contain no additives that may affect the sensitivity or otherwise reduce the effectiveness of the test.

    (G) Pressure test results. The commission or its delegate will consider, in evaluating the results of a test, the level of pollution risk that loss of well integrity would cause. Factors that may be taken into account in assessing pollution risk include injection pressure, frequency of testing and monitoring, and whether there is sufficient surface casing to cover all zones containing usable-quality water. A pressure test may be rejected by the commission or its delegate after consideration of the following factors:

      (i) the degree of pressure change during the test, if any;

      (ii) the level of risk to usable-quality water if mechanical integrity of the well is lost; and

      (iii) whether circumstances surrounding the administration of the test make the test inconclusive.

  (5) Alternative testing methods.

    (A) As an alternative to the testing required in paragraph (2) of this subsection, the tubing-casing annulus pressure may be monitored and included on the annual monitoring report required by subsection (i) of this section, with the authorization of the commission or its delegate and provided that there is no indication of problems with the well. Wells that are approved for tubing-casing annulus monitoring under this paragraph shall be tested in the manner provided under paragraph (3) of this subsection at least once every ten years after January 1, 1990.

    (B) The commission or its delegate grant an exception for viable alternative tests or surveys or may require alternative tests or surveys as a permit condition.

  (6) The operator shall notify the appropriate district office at least 48 hours prior to the testing. Testing shall not commence before the end of the 48-hour period unless authorized by the district office.

  (7) A complete record of all tests shall be filed in duplicate in the district office within 30 days after the testing.

Cont'd...

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